The US withholds 15% on dividends paid to Canadians. Here's how to minimize or eliminate this drag depending on where you hold your investments.
When a US corporation pays a dividend to a non-US investor, the IRS withholds a portion of the payment as withholding tax. For Canadian residents, the Canada-US Tax Convention reduces the standard 30% non-resident withholding rate to 15% on most dividends.
This means if Apple pays you a $100 dividend, the IRS withholds $15 before the money reaches your account. You receive $85.
| Account | Withholding Rate | Recoverable? |
|---|---|---|
| Non-registered (taxable) | 15% | Yes — foreign tax credit (T2209) |
| RRSP or RRIF | 0% | Not applicable — no withholding |
| TFSA | 15% | No — permanently lost |
| RESP | 15% | No — permanently lost |
| LIRA / LIF / PRPP | 0% | Not applicable — treaty covers these |
The Canada-US Tax Treaty specifically recognizes RRSPs and RRIFs as pension plans. Article XVIII of the treaty provides that income earned inside these accounts is exempt from US withholding tax. This is a significant benefit that makes RRSPs the optimal account for US dividend-paying stocks and ETFs.
If you hold US dividend stocks in a non-registered (taxable) brokerage account:
In most cases, the foreign tax credit fully offsets the US withholding, resulting in no double taxation in non-registered accounts.
To minimize withholding tax drag:
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| Country | Dividend Withholding Rate (Treaty) |
|---|---|
| United States | 15% |
| United Kingdom | 15% |
| Germany | 15% |
| France | 15% |
| Switzerland | 15% |
| Japan | 15% |
| No treaty countries | 25–30% |
US REITs pay distributions that are subject to 30% US withholding tax (not reduced to 15% under the treaty) for Canadian investors in non-registered accounts. In an RRSP, US REIT distributions are exempt from withholding under the treaty. This is another strong argument for holding US REITs in an RRSP rather than a TFSA or non-registered account.
The RRSP is the single most effective tool for eliminating US withholding tax — the treaty exemption saves 15% on every US dividend, compounding significantly over time. The TFSA, despite its otherwise excellent tax-free status, is the worst account for US dividend investments due to the permanent, unrecoverable 15% withholding. Strategic account placement is one of the highest-value tax optimizations available to Canadian investors.